This Privacy Policy describes how VinHMS Software Production and Trading Joint Stock Company (“Company”) collects and uses your personal information in relation to our websites, applications, products, and services (together, “Our Offerings”).

This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own Privacy Policy.

1. Personal Information We Collect
2. How We Use Personal Information
3. Collection and use of cookies
4. How We Share Personal Information
5. Location of Personal Information
6. How We Secure Information
7. Internet Advertising and Third Parties
8. Access and Choice
9. Juvenile’s Personal Information
10. Retention of Personal Information
11. Contacts, Notices, and Revisions
12. Additional Information for the EU
13. Examples of Information Collected

1. Personal Information We Collect

We collect your personal information in the course of providing Our Offerings to you.

Here are how we collect your information:

• Information You Give Us: We collect any information you provide in relation to Our Offerings.
• Automatic Information: We automatically collect certain types of information when you interact with Our Offerings.
• Information from Other Sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources.

2. We Use Personal Information

We use your personal information to operate, provide, and improve Our Offerings. Our purposes for using personal information include:

• Provide Our Offerings: We use your personal information to provide and deliver Our Offerings and process transactions related to Our Offerings, including registrations, subscriptions, purchases, and payments.
• Measure, Support, and Improve Our Offerings: We use your personal information to measure the use of, analyze the performance of, fix errors in, provide support for, improve, and develop Our Offerings.
• Recommendations and Personalization: We use your personal information to recommend Our Offerings that might be of interest to you, identify your preferences, and personalize your experience with Our Offerings.
• Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information.
• Communicate with You: We use your personal information to communicate with you in relation to Our Offerings via different channels (e.g., email, chat) and to respond to your requests.
• Marketing: We use your personal information to market and promote Our Offerings. We might display interest-based ads for Our Offerings.
• Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, us, and others. We may also use scoring methods to assess and manage credit risks.
• Purposes for Which We Seek Your Consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.

3. Collection and use of cookies

We use cookies, pixels, and other similar technologies (collectively, “cookies”) to recognize your browser or device, learn more about your interests, provide you with essential features and services, and for other additional purposes, including:

• Recognize you when you sign in using our offerings. This allows us to provide you with recommendations, display personalized content, and provide other customized features and services.
• Keep track of your specified preferences. This allows us to honor your likes and dislikes, such as your language and configuration preferences.
• Conduct research and analysis to improve our offerings.
• Prevent fraudulent activity.
• Improve security.
• Deliver content, including ads, relevant to your interests on our sites and third-party sites.
• Measure and analyze the performance of Our Offerings.

Cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you might not be able to use certain offerings that require you to sign in, or you might have to manually adjust some preferences or language settings every time you visit our sites.

Approved third parties may also set cookies when you interact with Our Offerings. Third parties usually include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on our behalf.

You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

4. How We Share Personal

Information Information about our customers is an important part of our operation and we are not in the business of selling our customers’ personal information to others. We share personal information only as described below. We also share personal information with Vingroup and its subsidiaries, all of these companies are subject to this Privacy Policy or similar policies.

• Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through Our Offerings. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party.
• Third-Party Service Providers: We employ other companies and individuals to perform certain functions on our behalf. Examples include: sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must adhere to this Privacy Policy and the applicable data protection law.
• Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the Privacy Policy (or the individual consents otherwise). Also, in the event that [_P&L_] or substantially all of its assets are acquired, your information will of course be one of the transferred assets.
• Protection of Us and Others: We release account and other personal information when we believe release is appropriate to comply with the law, court order, or any other legal obligation, enforce or apply our terms and other agreements, or protect the rights, property, or security of us, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
• At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have the right to choose not to share the information.

5. Location of Personal Information

The Company is located in Vietnam, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with Our Offerings, your personal information may be stored in or accessed from multiple countries, including Vietnam. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.

6. How We Secure Information

At the Company, security is our highest priority. We design our systems with your security and privacy in mind.

• We employ appropriate technical and security measures to prevent unauthorized access and use of your personal information. We also regularly cooperate with security experts to be updated with the latest information on network security to ensure the safety of your personal information. When collecting data, we maintain and secure your personal information at a server system and this information is secured by firewalls, access control measures, and data encryption.
• The information of your card, which is issued by the relevant financial institution, is protected by us in accordance with international standards on the principle that no important data of the card (card numbers, full names, CVV number) is recorded in our system. Your payment transaction is made by the relevant bank system.
• The security system of The Company obtained the Certification of Level 3 PCI DSS (Payment Card Industry Data Security Standard)

7. Internet Advertising and Third Parties

Our Offerings may include third-party advertising and links to other websites and applications. Third-party advertising partners may collect information about you when you interact with their content, advertising, or services.

8. Access and Choice

You can view, update, and delete certain information about your account and your interactions with Our Offerings. If you cannot access or update your information yourself, you can always contact us for assistance.

You have choices about the collection and use of your personal information. Many of Our Offerings include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of some of Our Offerings.

• Account Information: If you want to add, update, or delete information related to your account, please send us an email at info@vinhms.com. When you update or delete any information, we usually keep a copy of the prior version for our records.
• Communications: If you do not want to receive promotional messages from us, please send us an email at info@vinhms.com. If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device.
• Advertising: If you don’t want to see interest-based ads, please send us an email at info@vinhms.com.
• Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

9. Juvenile’s Personal Information

If you’re under 18, you may enter into contracts and accept this Privacy Policy only with the approval of your parent or guardian.

10. Retention of Personal Information

We keep your personal information to enable your continued use of Our Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

11. Contacts, Notices, and Revisions

If you have any concerns about privacy at VinHMS or want to contact one of our data controllers, please contact us and we will try to resolve it. You may also contact us at the address below:

• VinHMS Software Production and Trading Joint Stock Company
• Address: 188 Vo Thi Sau Street, Ward 7, District 3, Ho Chi Minh City, Vietnam
• Tel.: ( 84) 28 7109 9708
• Email: info@vinhms.com

Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. We will never materially change our Privacy Policy to make them less protective of personal information collected in the past without informing the relevant customers and giving them a choice.

12. Additional Information for the EU

We provide additional information about the privacy, collection, and use of personal information of prospective and current customers of Our Offerings located in the European Economic Area.

• Controller of Personal Information. The Company (at,188 Vo Thi Sau Street, Ward 7, District 3, Ho Chi Minh City, Vietnam) is the controller of the personal information collected or processed under this Privacy Policy.
• Processing. We process your personal information on one or more of the following legal bases:
  • as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Our Offerings, to respond to requests from you, or to provide customer support;
  • where we have a legitimate interest, as described in Section 2 of this Privacy Policy;
  • as necessary to comply with relevant law and legal obligations;
  • respond to lawful requests and orders; or
  • with your consent.
• Your Rights. Subject to applicable law, you have the right to:
  • ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
  • request that inaccurate personal information be corrected;
  • request deletion of personal information that is no longer necessary for the purposes underlying the processing processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
  • request us to restrict/stop the processing of personal information where the processing is inappropriate;
  • object to the processing of personal data;
  • request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means; and
  • lodge a complaint with the supervisory authority.

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us. If you wish to do any of these things and you are our customer, please contact us. If you are not our customer, please contact us at the address under Section 11 above.

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

Transfers outside of the EU. When we transfer your personal information outside the EU we do so in accordance with the terms of this Privacy Policy and applicable data protection law. This may include the transfer of data pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission.

13. Examples of Information Collected

Information You Give Us

You mainly provide information to us when you:

• search for, subscribe to, or purchase Our Offerings;
• create or administer your account;
• configure your settings for, provide data access permissions for, or otherwise interact with Our Offerings;
• register for or attend a Company’s event;
• purchase or use content, products, or services from third-party providers through Company’s websites or apps (or other similar venues operated or provided by us);
• offer your content, products, or services on or through Our Offerings or Company’s websites or apps (or other similar venues operated or provided by us);
• communicate with us;
• complete a questionnaire or other information request forms;
• post on Company’s websites or apps or similar venues.

Depending on your use of Our Offerings, you might supply us with such information as:

• your name, email address, physical address, phone number, and other similar contact information;
• payment information, including credit card and bank account information;
• information about your location;
• information about your organization and your contacts, such as colleagues or people within your organization;
• usernames, aliases, roles, and other authentication and security credential information; content of feedback, testimonials, inquiries, communications with us;
• your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend an event of Company or use certain Our Offerings
• information regarding identity, including government-issued identification information;
• corporate and financial information; and
• VAT numbers and other tax identifiers.

Automatic Information

We mainly collect information automatically when you:

• visit, interact with, or use Our Offerings (including when you use your computer or other devices to interact with Our Offerings);
• download content from us;
• open emails or click on links in emails from us; and
• interact or communicate with us.

Examples of the information we automatically collect include:

• network and connection information, such as the Internet protocol (IP) address used to connect your computer (or other devices) to the Internet and information about your Internet service provider;
• computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
• the location of your device or computer;
• authentication and security credential information;
• content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads;
• Our Offerings metrics, such as offering usage, occurrences of technical errors, reports, your settings preferences, backup information, API calls, and other logs;
• the content you viewed or searched for, page response times, and page interaction information (such as scrolling, clicks);
• email addresses and phone numbers used to contact us; and
• identifiers and information contained in cookies.

Information from Other Sources

Examples of information we receive from other sources include:

• marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information;
• subscription, purchase, support, or other information about your interactions with products and services offered by us or third parties in relation to Our Offerings;
• search results and links, including paid listings (such as Sponsored Links); and
• credit history information.